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1
2 -----------------------------------------------------
3 In the Matter of the Complaint of
Rep. Steve Drazkowski regarding the
4 Neighbors for Ilhan (Omar) Committee
5 -----------------------------------------------------
6
7 The DEPOSITION of CARLA C. KJELLBERG, taken by
8 Kassie Lahti Beebe, Court Reporter, a Notary Public
9 in and for the County of Wright, State of Minnesota,
10 taken on the 28th day of November, 2018, at the
11 offices of the Minnesota Campaign Finance & Public
12 Disclosure Board, 190 Centennial Office Building,
13 658 Cedar Street, St. Paul, Minnesota, commencing at
14 approximately 10:00 a.m.
15
16
17
18
19
20
21
22
23
24
25

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1 A P P E A R A N C E S
2 APPEARING FOR AND ON BEHALF OF THE MINNESOTA CAMPAIGN
FINANCE & PUBLIC DISCLOSURE BOARD:
3
JEFF SIGURDSON, EXECUTIVE DIRECTOR
4 MEGAN ENGELHARDT, ASSISTANT EXECUTIVE DIRECTOR
MINNESOTA CAMPAIGN FINANCE & PUBLIC
5 DISCLOSURE BOARD
190 Centennial Office Building
6 658 Cedar Street
St. Paul, Minnesota 55155-1603
7
jeff.sigurdson@state.mn.us
8 megan.engelhardt@state.mn.us
9 APPEARING FOR AND ON BEHALF OF THE WITNESS:
10 K. DAVIS SENSEMAN, ATTORNEY AT LAW
DAVIS LAW OFFICE
11 400 South Fourth Street
Suite 401
12 Minneapolis, Minnesota 55415
13 davis@davismeansbusiness.com
14
15
16 *The Original is in the possession of the
Minnesota Campaign Finance & Public
17 Disclosure Board.*
18
19
20 * * *
21
22
23
24
25

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1 I N D E X
2 CARLA C. KJELLBERG PAGE
3 Examination by Ms. Engelhardt ................... 4
4
5
6 * * *
7
8
9 E X H I B I T S
10 NUMBER DESCRIPTION PAGE MARKED
11 1 Affidavit 4
12 2 8/16/16 Email 4
13 3 8/31/16 Email 4
14 4 9/15/16 Email 4
15 5 3/30/17 Email 4
16 6 Register of Actions 4
17 7 7/27/17 Report 4
18 8 2/2/18 Report 4
19
20
21 * * *
22
23
24
25

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1 (Whereupon Exhibit Numbers 1-8 were

2 marked for identification by the court
3 reporter.)
4 P R O C E E D I N G S
5 CARLA C. KJELLBERG,
6 after having been duly sworn, was examined and
7 testified on her oath as follows:
8
9 EXAMINATION
10 BY MS. ENGELHARDT:
11 Q Thank you for taking the time to come in
12 here. I'm Megan Engelhardt. I'm the assistant
13 executive director with the Campaign Finance Board.
14 So the reason we're here is we're conducting an
15 investigation regarding some expenditures that were
16 made by the Neighbors for Ilhan Committee in 2016,
17 and specifically payments that were made to your law
18 firm, so we wanted to discuss it with you. I know
19 that you're a lawyer so you've probably had
20 depositions before.
21 A Yes, I have.
22 Q So you know the general rules. We'll all
23 remind ourselves because I know we'll all need them.
24 We'll try not to talk over each other. We'll use
25 verbal answers instead of nodding and uh-huh. And

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1 again, if there's anything -- a question doesn't make

2 sense, stop me and let me know. We'll all try our
3 best not to talk over each other. I tend to do that
4 a lot.
5 A I understand those. I tend to pause when
6 I'm asking questions or answering, so I give you that
7 bit of information. Maybe it will help.
8 Q Good, all right. Excellent. Would you
9 please state your full name for the record and spell
10 your last name?
11 A Carla C. Kjellberg. Last name is spelled
12 K-J-E-L-L-B-E-R-G.
13 Q And I know you're a lawyer, and where do
14 you currently work?
15 A I work -- 2356 -- it's my own private
16 practice, Kjellberg Law Office, 2356 University
17 Avenue, Suite 230, St. Paul. I am missing the zip
18 code in my head right now, but you can look it up if
19 you need it.
20 Q Well, thank you. Well, let's just talk a
21 little bit generally about the Omar Committee. When
22 did you become involved with the Neighbors for Ilhan
23 Committee?
24 A I did not refresh dates, although I have
25 emails here that would refresh them, but there was a

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1 crisis that happened which was that -- I believe it

2 was Power Line or it might have been Alpha News, had
3 published something alleging that Ilhan was not
4 really married to the person she claimed was her
5 husband and was married to another man, and they made
6 the allegation that it was her brother in order to
7 get some sort of benefit with regard to immigration.
8 And the first attempt to deal with that by the
9 committee was not effective, and so there was a call
10 to people that had done crisis management work and I
11 was one of those people.
12 Q So you were not involved before that?
13 A I was not.
14 Q Okay. Do you recall what the first sort of
15 attempt was to resolve that was and when that was?
16 A I believe what they did was ignore it. I
17 can't remember. I can't remember. They may
18 have -- they may have responded to Power Line
19 or -- all I remember is that it was not effective.
20 And there was an opinion expressed by other people in
21 the meeting that I was in, which actually occurred in
22 my condo, that don't worry about it. The legitimate
23 press won't cover it. I expressed a different
24 opinion.
25 Q Do you recall when that meeting was?

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1 A Not offhand.
2 Q Okay.
3 A I believe it was a Saturday or a Sunday,
4 and it would have been -- if you look at the emails,
5 it would have been probably days before the first
6 email on this or the day before.
7 Q Okay.
8 A And I think you have those.
9 MS. SENSEMAN: Yeah, we sent some of
10 those over with the --
11 MS. ENGELHARDT: Yes, we do have
12 those.
13 MS. SENSEMAN: Way back when --
14 MR. SIGURDSON: Just to set a time
15 frame, almost all those emails are from August
16 of 2016.
17 THE WITNESS: Thank you. So that's
18 when the crisis was happening before the general -- or
19 just after. That would have been just after the --
20 MS. SENSEMAN: After the primary.
21 THE WITNESS: After the primary,
22 right.
23 BY MS. ENGELHARDT:
24 Q So it was after the primary?
25 A Right.

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1 Q Okay. Did you have an official role with

2 the Omar Committee?
3 A I believe my official role was with the
4 crisis management committee and that was fairly
5 formal. We had members and there was a member from
6 the campaign that sat in on those meetings. That was
7 Lena Gardner.
8 Q And can you recall who else was on the
9 crisis management team?
10 A I'm sorry. I want to say Blodgett, but
11 it's not Blodgett. It's the other -- he ran
12 Wellstone Action for a long time. His name is
13 leaving me, but it's in those emails.
14 MR. SIGURDSON: Would the name
15 perhaps be Ben Goldfarb?
16 THE WITNESS: It would be
17 Ben Goldfarb. And then there was someone else that I
18 did not know who was associated -- his experience was
19 with the -- one of the, perhaps, the DFL caucus or
20 something that was directly connected to either the
21 Democratic majority at that -- well, minority at that
22 time in the House or -- I don't think it was the party
23 itself.
24 MR. SIGURDSON: Would that be
25 Michael Howard?

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1 THE WITNESS: It would.

2 MR. SIGURDSON: My role will be to
3 occasionally interject questions that frankly occur to
4 me, I guess. I mean, clearly Megan has a better
5 understanding of the documentation that we received in
6 response to our inquiries.
7 But I just want to stop here. You said
8 something that I thought was interesting. You said
9 that you thought there was one member on the campaign
10 committee, on the crisis management committee, which
11 to me implies that was somehow separate from the
12 campaign committee. In your view, was the crisis
13 committee not really part of the campaign?
14 THE WITNESS: I can't really talk
15 about how they viewed it. We answered to Ilhan and
16 the campaign, that Lena was there to share information
17 and get direction at times from the campaign. So I
18 would see it as a -- you know, I would see it as a
19 specialist committee that was formed in order to give
20 help to the campaign committee.
21 MR. SIGURDSON: Would you say it was
22 formed by the campaign committee?
23 THE WITNESS: Yes.
24 MR. SIGURDSON: Okay, thank you.
25

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1 BY MS. ENGELHARDT:
2 Q And you mentioned that part of the reason
3 that they reached out to you was because you had done
4 previous work for crisis management?
5 A Correct.
6 Q And was that for other campaigns?
7 A Yes.
8 Q Okay. And have you had any other
9 experience with any other campaigns?
10 A I have. Primarily Keith Ellison. So I
11 have had a dual role with Keith Ellison, and I have
12 been his lawyer and I have been the campaign's
13 lawyer. I have also been a political advisor and a
14 number of that would involve campaign or crisis
15 management.
16 I have never charged for my political work
17 to Keith Ellison, nor did I to Ilhan. So I have
18 always been very careful in my work with political
19 people to charge only for my legal work, and I do not
20 consider my political work to be something that I
21 make a living on. I know that's more than your
22 question, but --
23 Q No, I appreciate it. Can you talk a little
24 bit about the crisis management team and what your
25 first kind of thoughts were about the crisis?

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1 A I'm just trying to figure out in my own

2 head whether any of the information that I'm giving
3 you is --
4 MR. SIGURDSON: Perhaps at this
5 point --
6 THE WITNESS: Were all related --
7 MR. SIGURDSON: I was going to
8 suggest that we did bring a few of the emails --
9 THE WITNESS: Um-hmm.
10 MR. SIGURDSON: -- as exhibits, and
11 the one dated August 16th from Lena Gardner and then
12 basically everybody else on the committee. We can
13 introduce that now to help --
14 MS. ENGELHARDT: Sure.
15 MR. SIGURDSON: This email seems to
16 spell out the roles of every member of the committee.
17 If you could take just a minute to read that and tell
18 us if you believe that's accurate information about
19 the crisis committee.
20 THE WITNESS: Yes, that that is an
21 accurate description, and nothing else to add to that.
22 BY MS. ENGELHARDT:
23 Q Was this email, do you think, before -- you
24 had originally said you met earlier and the decision
25 was to do nothing. I'm assuming this was after that?

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1 A It was after that.

2 Q Okay, all right. And what was your first
3 steps that you wanted to take as legal advisor?
4 A Well, as legal advisor, which I think was
5 after this, not what I expressed in the meeting. I
6 was not a legal advisor in the meeting that was in my
7 condominium. So I don't know exactly, but my first
8 advice -- so legal advice, as a legal advisor, I
9 expressed the opinion that we needed to know what all
10 is out there.
11 So we needed to know if there were any
12 financial issues. We needed to know whether there
13 was any -- is there something in this immigration
14 file that would hurt Ilhan and the campaign? There
15 were a number of allegations. Most of them we felt
16 were false. At this time there were rumors that, you
17 know, somebody had received a copy of the file and
18 had found that something existed. I mean, there was
19 a lot of chatter.
20 So my first advice is we have to find out
21 what's there. Now, when you say -- so I
22 also -- there's also a political element here on the
23 committee I would express that I would not consider a
24 legal opinion. And at that time we were still in
25 the, we don't need to issue a statement by Ilhan. I

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1 vehemently disagreed with that and expressed that --

2 as an opinion, that in fact because of racism, we
3 absolutely did have to issue an opinion. So it's
4 hard for me to determine exactly which is which, but
5 both of those things were happening along the same
6 line.
7 Q Did the Neighbors for Ilhan Committee
8 retain your law firm?
9 A No. I -- well, there's no formal retainer,
10 and I was not charging for legal services. My role
11 as legal advisor was limited to the advice in
12 obtaining of the services from Tom Rosen and
13 Bruce Nestor.
14 Q Okay. So there's no retainer agreement
15 that you have?
16 A Correct.
17 Q Who would you have considered to be your
18 client?
19 A For that limited purpose, I believe I
20 considered both Ilhan and the campaign to be my
21 client.
22 Q So can you talk about who you reported your
23 findings to?
24 A So the information that was gathered from
25 Tom Rosen was reported to both Ilhan and the

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1 committee.
2 Q When you say the committee, do you mean the
3 crisis management team?
4 A The crisis management team.
5 Q Not the campaign committee?
6 A Not the campaign committee, because my
7 understanding of the reporting was that Lena would be
8 reporting the important information to the campaign
9 committee.
10 Q Okay.
11 MR. SIGURDSON: Just --
12 THE WITNESS: And then Bruce Nestor,
13 that came in after the crisis abated. I'm not sure if
14 it was after the election, but it was after the crisis
15 abated. And the committee was not meeting, and I
16 shared that information, basically that the -- that
17 the file was not obtainable with Ilhan.
18 BY MS. ENGELHARDT:
19 Q Okay. Well, let's back up a little bit.
20 So your main purpose for legal advisor was to obtain
21 documents, you said. So what kind of documents were
22 you looking for? Well, I think you said files.
23 A Well, that was for Bruce Nestor.
24 Q Okay.
25 A That her -- everybody has an immigration

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1 file. So I was -- who was not born in this country.

2 Q Um-hmm.
3 A And that's the file I was attempting to get
4 through Bruce Nestor because he's an immigration
5 lawyer and he is accustomed with how that process
6 works and how to do that.
7 I don't think I said that I was receiving
8 documents from Tom Rosen. I think what I said was
9 that I secured Tom Rosen for the purpose of
10 determining whether there were any financial issues.
11 He's an accountant that needed to be dealt with
12 before -- if they were -- you know, if there's some
13 kind of information in there that would look badly on
14 Ilhan.
15 Q Okay. Well, let's, if you don't
16 mind -- oh, go ahead.
17 MR. SIGURDSON: I want to step in,
18 just to make sure I understand. Again, going back to
19 the email you -- described to you as Carla serving as
20 our legal advisor for statements and strategies for
21 the campaign and for Ilhan personally. There isn't
22 anything in the email indicating that you would be
23 seeking the immigration file or contacting the Rosen
24 firm. Was that decision or authorization to do that
25 provided at a later date? And if so, by who?

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1 THE WITNESS: My memory is that it

2 was the crisis committee. It was a later date. It
3 was when we were meeting. So if you look at the
4 crisis, it started and then it ended. And it ended
5 when Andy Luger issued a statement that said we are
6 not investigating. Because there was a leak, I can't
7 remember which reporter, but I believe it was
8 Channel 5. I believe it was the same reporter that
9 did the thing about Pointergate --
10 MS. SENSEMAN: It was.
11 THE WITNESS: -- who made the
12 comment that he was told that Andy Luger, who was then
13 the U.S. Attorney, was going to be investigating
14 Ilhan, that they had gotten the file. I can't
15 remember all the other things.
16 So in between beginning of the crisis,
17 which is sometime in early August, and I believe late
18 August that we could find it with Andy Luger's
19 statement, and I believe it's in my emails, that it
20 was clear that we needed to know what was in that
21 file.
22 MR. SIGURDSON: So the crisis
23 committee, from your recollection, authorized you to
24 engage these other firms to get information that might
25 be relevant to understanding the scope of the crisis,

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1 or perhaps responding to the crisis. So that provided

2 authorization. Do you recall any conversations with
3 Representative Omar on these issues? At some point
4 she had to --
5 THE WITNESS: She was in all of
6 these meetings.
7 MR. SIGURDSON: Okay.
8 THE WITNESS: I did nothing, I want
9 to make that clear, without Representative Omar's
10 authority. And she was in these meetings where those
11 things were decided upon and I was directed to do
12 that.
13 MR. SIGURDSON: Okay, thank you.
14 MS. ENGELHARDT: I don't believe we
15 have an email that refers to the Andy --
16 MR. SIGURDSON: I don't believe we
17 do, either.
18 MS. SENSEMAN: I can check and see
19 if we have that. I'm sure we probably do.
20 BY MS. ENGELHARDT:
21 Q If you don't mind, can we talk about
22 deposition -- this is Exhibit Number 1. This was the
23 affidavit that you provided.
24 A Um-hmm.
25 Q So let's take a look at the first exhibit

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1 of your affidavit, which is Exhibit 1. I have a

2 couple of questions about it. So the date on this is
3 August 16th conference with Ilhan. Is that the date
4 of the meeting that you were talking that's referring
5 to this email?
6 A No.
7 Q This is a separate conference?
8 A Separate conference. It was at the same
9 time. It was clear to everyone that she needed to
10 get a divorce from this man she was married to.
11 Q Okay. So this Exhibit 1, at the top it
12 says divorce?
13 A Um-hmm.
14 Q Okay. And then it says conference with
15 Ilhan. So this billing statement is about the
16 divorce?
17 A This billing statement is combined.
18 Q Okay.
19 A The time is referenced with the divorce.
20 The costs are with regard to the campaign.
21 Q And that's the Frederick & Rosen?
22 A Correct.
23 Q $1,500?
24 A Correct.
25 Q Okay. Is there a reason you put them in

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1 the same file?

2 A Because my assistant is an old dog that
3 does it her way. And she would tell me if I asked to
4 divide it, that that would require this, this, this,
5 and this, and it was unnecessary. And it would have
6 been an hour and a half that I didn't have.
7 Q Okay.
8 A I tell the truth.
9 Q Okay, all right. So the Frederick & Rosen
10 services are really for the crisis management?
11 A Correct.
12 Q And this conference with Ilhan is related
13 to the divorce?
14 A Correct.
15 Q Okay. This billing statement is dated
16 August 31, 2016.
17 A Okay.
18 Q Is it your office's practice to send out
19 monthly billing statements to clients?
20 A Yes, it is.
21 Q Okay. So this would have been sent to
22 Representative Omar on the 31st or maybe thereabouts?
23 A Yes, it would have been mailed -- could
24 have been mailed the next day. It may have been
25 emailed that day, but it goes out when it is

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1 produced.
2 Q Okay.
3 A Because there's drafts, but I believe that
4 the date is the final production.
5 Q Okay. So if you take a look at the next
6 page of Exhibit 1. There's a September 1, 2016,
7 statement from Frederick & Rosen, and this is from
8 the accountants, right?
9 A Um-hmm.
10 Q And this would have been included with this
11 bill?
12 A We must have gotten an earlier one based on
13 the dates and this must have been the second billing,
14 or it came -- well, actually, I believe it came by
15 email. I knew what the -- I don't know. I can look
16 to see if we have an earlier statement, but I am sure
17 that this is not the statement that was included in
18 the bill. It's -- my assistant must have just pulled
19 the statement when she was preparing this.
20 Q Okay. So let's look at the Frederick &
21 Rosen statement. So they are certified public
22 accountants?
23 A Correct.
24 Q And why did the crisis management team want
25 them to do work?

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1 A I don't know if I consider this potentially

2 confidential. Counsel is not objecting, so I don't
3 know if you want me to answer.
4 MS. SENSEMAN: Yeah, I mean, it's
5 likely privileged. The -- I mean, you had previously
6 stated that there were a number of allegations raised
7 against -- by this that created the crisis. So I
8 believe you had said they were gathering all of the
9 public information available, or private information
10 that someone could have possibly obtained, and that
11 went along with this, correct?
12 THE WITNESS: This was a specific
13 service that was performed, but the nature of the
14 service I believe is a confidential matter, a
15 privileged matter.
16 BY MS. ENGELHARDT:
17 Q Okay. Well, it looks like to me -- and
18 maybe you can at least correct me if I'm wrong -- it
19 looks like it was to provide tax returns for 2014 and
20 2015 for Mr. Hirsi and Ms. Omar?
21 A (No response.)
22 Q Okay. So would you say that the work for
23 Frederick & Rosen was related to the crisis, or was
24 it related to personal work for Representative Omar?
25 A Oh, it's definitely related to the crisis.

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1 I would not have had this done just for the -- this
2 was a crisis related, in at least timing, thing that
3 had to be done in the manner it was done.
4 Q Okay. And do you recall when you paid this
5 statement?
6 A I would have paid it prior to this because
7 I wouldn't have billed it. I think there is a -- I
8 thought there was a check in this. There's not, but
9 I would have paid it prior to this or I wouldn't have
10 billed it.
11 Q Okay, all right. Let's look at Exhibit --
12 MR. SIGURDSON: Before we go on, the
13 services provided by the Rosen firm, I'm assuming that
14 involved some documentation filed. Is that in your
15 possession or was that provided to Representative
16 Omar?
17 THE WITNESS: I believe it was
18 provided to Representative Omar. I do not know if I
19 have a copy.
20 MR. SIGURDSON: Is there any way
21 that you can identify what part of the accusations
22 that were being made against Representative Omar that
23 the crisis team was responding to, what part of those
24 allegations might have referenced the information that
25 the Rosen firm provided to the crisis committee?

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1 THE WITNESS: It would have been

2 something discovered ancillary to the allegation that
3 her current marriage was not legal, or not -- what's
4 the word I want -- not recognized by the state or the
5 federal government, and that she was still married to
6 someone else.
7 MS. SENSEMAN: And a lot of the
8 allegations -- we can provide you an example of recent
9 ones. A lot of times they'll say, we think this is
10 the case and therefore that probably leads to -- and
11 then they make this string of, you know, financial,
12 this, that. They kind of just throw out a laundry
13 list of, like, here are the things that this could
14 possibly be. All the articles all seem to have the
15 same format. And they kind of at the end say, we
16 think this would prove all these different kinds of
17 criminal or different activity.
18 THE WITNESS: I will leave that
19 there.
20 BY MS. ENGELHARDT:
21 Q Do you know, did Representative Omar's
22 committee use any of the information that Frederick &
23 Rosen provided as part of her response?
24 A Probably not. That -- this was correcting
25 something that could have been detrimental to

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1 Ms. Omar.
2 MR. SIGURDSON: Would the issue that
3 was corrected, or potentially at least corrected,
4 through this information from the Rosen firm been
5 important for Representative Omar to correct
6 regardless of her status as a candidate?
7 THE WITNESS: Yes, but probably not
8 in the sense of urgency and necessity for
9 professionals to do.
10 BY MS. ENGELHARDT:
11 Q All right. Let's move on to Exhibit 2 of
12 your affidavit. Again, you have this part is billing
13 at the top, it still says divorce. But this is --
14 JMF, I assume, is --
15 A -- is Janet M. Fridgen.
16 Q Um-hmm. And mailing documents to
17 Bruce Nestor?
18 A Correct.
19 Q And then the Nestor immigration work, and
20 this is all dated September 14, 2016, correct?
21 A Well, it's not all dated.
22 Q The immigration work.
23 A The billing for the cost is dated 9/14.
24 Q So would that have been the day you paid
25 that bill?

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1 A I believe that is how my assistant does it.

2 She may have -- again, there are -- we work in a
3 billing system, in a system that is my assistant's
4 alone. That my way, when I'm looking at these
5 things, I'm looking at them to see if there's
6 anything that a client would find confusing. So I --
7 that's my assumption, that that's when it was paid.
8 Or it may have been when it was billed, but my guess
9 is that she would have paid it at the same time.
10 Q Well, let's look at Deposition
11 Exhibit Number 4. This is an email that, as you can
12 see at the bottom part, is sent Wednesday,
13 September 14th, and that's the attached billing from
14 Bruce Nestor?
15 A Um-hmm.
16 Q Okay. So does that make sense with the
17 billing, then?
18 A That it's dated September 14th. The bill
19 is dated September 14th. My guess is that we would
20 have written the check either on the 14th or slightly
21 after but prior to the issuance of the bill.
22 Q And the issuance of the bill, it looks like
23 it's dated 9/30/2016 --
24 A Correct.
25 Q So that's when it would have been sent to

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1 the Omar Committee?

2 A It was sent directly to Ilhan.
3 Q So on this page on the previous Exhibit 1
4 there's $80 worth of work from CCK time, and that's
5 you?
6 A Um-hmm.
7 Q And that was related to the divorce?
8 A Correct.
9 Q And on this page there's $12 worth of work
10 from JMF and $2.68 of copies and postage?
11 A Correct.
12 Q And this was related not to the divorce or
13 was it related to crisis management?
14 A This would have been related to the crisis
15 management.
16 Q Do you know, was that ever paid?
17 A Yes, it was paid by Ilhan.
18 Q Okay. The $12 -- $14.68?
19 A Correct.
20 Q Okay.
21 A As was the $80.
22 Q Okay. And the next page is the De León &
23 Nestor bill?
24 A Um-hmm.
25 Q And this is, it looks like, for immigration

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1 work, and it talks about preparing certain documents

2 for client to sign. And can you tell me a little bit
3 about what this work was?
4 A He was doing a Freedom of Information Act
5 request to get her immigration file.
6 Q Was he just looking for her immigration
7 file or was he looking for anybody else's?
8 A My memory is that just hers because the
9 assumption was based upon his advice, that if there
10 was any statement of support or anything with regard
11 to her legal husband, it would be in her file.
12 Q Do you recall, do you have a general date
13 for when you got this statement from Andy Luger
14 about --
15 A I can look. Hold on. I don't appear to
16 have it. I don't have it.
17 Q Okay.
18 A You have to remember, too, that when you're
19 in a political crisis like this, a week seems like a
20 month. So I -- you know, and every day the world's
21 going to fall apart or it isn't, and so it may just
22 have been a week, it may have been two weeks.
23 MS. SENSEMAN: It looks like
24 August 22 of 2016 is when the press reported on the
25 letter, when the letter was publicly -- and I believe

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1 Andy Luger made it public when he --

2 MS. ENGELHARDT: August 22nd?
3 MS. SENSEMAN: Yes, I believe that
4 was.
5 MS. ENGELHARDT: Okay.
6 BY MS. ENGELHARDT:
7 Q So looking at the De León & Nestor invoice,
8 it looks like there's three entries that happened
9 like mid-August, the 16th and the 17th, to set up the
10 file, to prepare the documents for signature, and
11 phone conference with you, correct?
12 A Correct.
13 Q Okay. And then there's, on August 31st
14 there's a phone conference with Representative Omar?
15 A Um-hmm.
16 Q And then all the return forms were for
17 September, September 6th and September 10th?
18 A Um-hmm.
19 Q Which is after -- the last three entries on
20 this bill are after the Andy Luger statement.
21 A Right. But the need to know what the file
22 says never went away. I mean, that ended the
23 immediate crisis, but we still don't know if somebody
24 else is making a request for this file. And so we
25 need to -- and the election isn't until November and

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1 something else can happen. So when I say that the

2 crisis was over, the immediate crisis was over, but
3 the need was not over.
4 Q Do you recall when you received the
5 documents from Mr. Nestor?
6 A I know they took a while. Yeah, we didn't
7 receive a response until March 30th.
8 Q Okay. And that's this email that he
9 forwarded to you?
10 A Yep.
11 Q That's Deposition Exhibit 5. Can you take
12 a look at Exhibit Number 3? And this is an email
13 from Mr. Nestor.
14 A Um-hmm.
15 Q It says she's been contacted about a claim
16 that ICE or USCIS has issued a summons. Do you
17 recall discussing that as part of the crisis
18 management?
19 A I don't see where that is.
20 Q It's the second paragraph of his email to
21 you.
22 A Oh, okay. Yes.
23 Q Was that something that you were also
24 pursuing as part of the crisis management?
25 A I don't know what you mean by pursuing.

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1 Q Well, that somebody was still contacting

2 about these claims that ICE or Immigration was
3 issuing summons. Was that something that the crisis
4 management was still concerned about?
5 A Yes.
6 Q Okay.
7 A Everybody that was involved in this crisis,
8 even though the immediate threat -- so let me explain
9 what the threat is, okay? The threat is that a
10 right-wing blog begins a false narrative based on
11 racial assumptions that could affect Ilhan's election
12 and Ilhan's standing. The legitimate media then runs
13 with that right-wing blog and it gains legitimacy.
14 That legitimacy fell drastically once Andy Luger said
15 that's false. The danger of something being said
16 again in the right-wing blog with anything is still
17 present. I mean, it's still present today.
18 So when I previously testified that it was
19 over when Andy Luger made the statement, what I meant
20 was, that sense of the world is falling apart, we
21 need to do something immediately, had lessened
22 greatly.
23 Q Okay.
24 MR. SIGURDSON: Just quickly, to tie
25 up something the other email on March 30, 2017, in

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1 which Mr. Nestor informs you and Representative Omar

2 that he received a response. It's on a CD disc. It's
3 also downloaded into a Dropbox. To your knowledge,
4 that was -- Representative Omar has a copy of the
5 material?
6 THE WITNESS: Yes.
7 MR. SIGURDSON: Okay.
8 BY MS. ENGELHARDT:
9 Q Okay. Let's turn to Exhibit 3 of your
10 affidavit.
11 A Um-hmm.
12 Q And the time that's listed at the top, this
13 is related to the divorce?
14 A This all related to the divorce.
15 Q Okay.
16 A There is a reference, the reason it is
17 included, I believe she paid off the bill.
18 Q On 12/15/2016?
19 A Yes.
20 Q It says, advance payment, thank you,
21 $2,250?
22 A Let me double-check. That's my
23 recollection.
24 Q Well, the math would total up the $750
25 and -- the $750 paid to De León & Nestor and the

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1 $1,500 to Frederick & Rosen, that would total to

2 $2,225 [sic]. Do you recall if that payment came
3 from Representative Omar personally or from the
4 committee?
5 A It came from Representative Omar.
6 Q Do you still have a copy of the check?
7 A I don't know if we do. I would assume we
8 do. We don't always make copies of checks that we
9 deposit.
10 Q Okay.
11 A And so I don't really know. We do have the
12 deposit slip, which is attached, but it's my memory
13 that she signed the check.
14 Q Okay. And this is Deposition Exhibit
15 Number 5. And this one is the materials that you
16 received March 30th?
17 A Yes.
18 Q It says, Bruce Nestor says, I can also
19 review the FOIA response and give my thoughts. I'd
20 charge $250 an hour. Did you or Representative Omar
21 take him up on that offer?
22 A I do not believe so.
23 Q Okay. And after 2016, did you stay
24 involved with the committee?
25 A No.

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1 Q So when would you say your involvement with

2 the committee ceased?
3 A Sometime prior to the election, but I don't
4 know exactly when.
5 Q Aside from this email that you got in 2017?
6 A Oh, I'm sorry. I misunderstood your
7 question. I am still responding -- I mean, I'm still
8 working on the directive with regard to the file for
9 Bruce Nestor. I thought you meant meeting with the
10 committee and doing active advisement. So this would
11 be the follow-up from that.
12 Q Okay. And you were still working with
13 Representative Omar personally regarding her divorce?
14 A Correct.
15 Q And that was throughout 2016 and 2017?
16 A Correct.
17 Q But you weren't providing any other
18 political services at that point?
19 A No.
20 Q Okay. Do you have any other information
21 you want to let us know about?
22 A I'm laughing as a lawyer. No.
23 Q Just thought I'd check. Do you have any
24 emails or any other that we don't have that would be
25 helpful?

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1 THE WITNESS: I will let Counsel

2 determine that.
3 MS. ENGELHARDT: Okay.
4 MR. SIGURDSON: In particular, in
5 communication with the crisis team, there was no
6 response to a press release or a statement by
7 Mr. Luger, would be useful.
8 MS. SENSEMAN: I'll check those,
9 yes.
10 MR. SIGURDSON: It will help us
11 understand the time frame for that.
12 MS. SENSEMAN: Sure.
13 MS. ENGELHARDT: I will say, I did
14 mark this as an exhibit. This is just the Register of
15 Actions for the divorce and the timeline.
16 THE WITNESS: Okay. That doesn't
17 seem to --
18 MS. ENGELHARDT: Okay. It's just a
19 Register of Actions.
20 THE WITNESS: There's no question
21 before me.
22 MS. ENGELHARDT: Nope.
23 MR. SIGURDSON: I think that we're
24 done.
25 THE WITNESS: If it's a formal

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1 deposition, I don't need to read and sign.

2 (Deposition concluded at 10:54 a.m.)
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1 STATE OF MINNESOTA)
)
2 COUNTY OF WRIGHT )
3 Be it known that I took the deposition of
CARLA C. KJELLBERG, on the 28th day of November,
4 2018, at the offices of the Minnesota Campaign
Finance & Public Disclosure Board, 190 Centennial
5 Office Building, 685 Cedar Street, St. Paul,
Minnesota;
6
That I was then and there a Notary Public in
7 and for the County of Wright, State of Minnesota, and
that by virtue thereof, I was duly authorized to
8 administer an oath;
9 That the witness before testifying was by me
duly sworn to testify the whole truth and nothing but
10 the truth relative to said cause;
11 That the testimony of said witness was recorded
in stenotype by myself and transcribed into
12 typewriting under my direction, and that the
deposition is a true record of the testimony given by
13 the witness to the best of my ability;
14 That the cost of the original transcript has
been charged to the party noticing the deposition
15 unless otherwise agreed upon by Counsel, and that
copies have been made available to all parties at the
16 same cost, unless otherwise agreed upon by Counsel;
17 That I am not related to any of the parties
hereto nor interested in the outcome of the action;
18
That the reading and signing of the deposition
19 by the witness and the Notice of Filing were waived.
20 Witness my hand and seal this 4th day of
December, 2018.
21
22
23
___________________________
24 KASSIE LAHTI BEEBE
Court Reporter
25

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